CRWIA – Stage 3
CRWIA title: (CRW)IA on Reducing risks in schools guidance for back to school arrangements - August 2021
Summary of policy aims and desired outcomes
The updated Reducing Risks in Schools guidance should be used by schools and local authorities in planning for the 2021/22 school session. The guidance sets out that local authorities and schools should continue to apply the mitigations that were in place at the end of last term, with the exception of some modifications relating to an updated policy on self-isolation, contact tracing and testing for U18 close contacts and minor adjustments to ensure consistency with the mitigations in place in wider society. These adjustments should be made as soon as possible after the return to school, and in any case within 6 weeks of return (end of September).
The policy aims to support a safe return to school for all children, young people and staff from 11 August 2021.
This impact assessment considers the impacts to children's rights and wellbeing as a result of policy updates to self-isolation, contact tracing and testing for U18 close contacts and minor adjustments to mitigations to ensure consistency with the mitigations in place in wider society.
The assessment specifically considers children and young people who may be more adversely affected by the updated policy on self-isolation, contact tracing and testing, and adjustments to mitigations and the actions taken to mitigate the impact of those changes.
Assessment of the updated Reducing risks in schools guidance has found that the amendments to mitigation measures conveys a largely positive impact on the UNCRC for all children and young people in their return to school after the summer break.
Where negative impacts have been identified, mitigation measures have been put in place to minimise any reduction in the rights and wellbeing of children and young people as laid out in the UNCRC and the Scottish Government's GIRFEC framework.
As part of the ongoing response to the COVID-19 pandemic, on 6 April, following assessment of the latest data and advice from clinical advisors, the First Minister announced that that almost all pupils would return to school for in-person learning following the Easter break. This return coincided with an investment of almost £400m of funding to help with education recovery and updated guidance for ensuring a safe return including; a removal of strict 2m distancing where necessary and encouragement for all secondary pupils and staff to engage in twice weekly lateral flow testing which was made available for monitoring purposes. The measures remained in place for the remainder of the school term.
At the end of term, schools were advised that current mitigations would remain in place upon the return to school from the summer break. This was to provide a measure of security for local authorities and teachers over the summer period and allow them to better plan for the return to school in the new term in August.
During summer an enhanced summer offer was made available to mitigate some of the negative social, learning and development impacts from schooling interruptions, along with continued provision of free school meals to support those families impacted most by the COVID-19 pandemic.
Professionals from across the education and Early Learning and Childcare (ELC) sectors have taken action to support children and young people through these challenging times. However, interrupted schooling is considered to be having a negative effect on all aspects of children's progress and development, including their learning and their wellbeing, including their mental health.
The Scottish Government has taken a series of actions, together with partners, to mitigate these impacts wherever possible, and to secure the wellbeing of children and young people as we return to in-person learning at school.
The Scottish Government COVID-19 Advisory Group was established in March 2020 to apply the advice coming to the four nations from the Scientific Advisory Group on Emergencies (SAGE) and other appropriate sources of evidence and information and use it to inform local decisions in Scotland during the pandemic. Later, a sub-group specialising in children's and education issues was also established to provide more bespoke advice. This includes providing insight and modelling to ministers and the COVID-19 Education Recovery Group (CERG).
The CERG was established in April 2020 to support government decision making through providing insight into the practicalities around reopening schools and ELC settings. The focus of the group is on how schools should operate based on the latest scientific advice on issues affecting children and young people and their schooling.
The Scottish Government also takes advice from the JCVI which is used to guide ministerial decisions in relation to vaccination policy and delivery across Scotland.
The guidance under assessment sets out that local authorities and schools should continue to apply the mitigations that were in place at the end of last term, with the exception of some modifications relating to an updated policy on self-isolation, contact tracing and testing for U18 close contacts.
Scope of the CRWIA, identifying the children and young people affected by the policy, and summarising the evidence base
The CRWIA applies to all children and young people who are on the school roll of an independent, grant aided or education authority school in Scotland, who are aged up to 18 years of age. It is recognised that there are some young people on the school roll in Scotland who are aged 19, to whom this would apply, although the scope is limited to 18 year olds.
There is a significant evidence base to support the decisions to update policy on self-isolation, contact tracing and testing for U18 close contacts in the form of government reports, independent analysis and 3rd sector surveys.
Officials have reflected the information gathered through statistical evidence and data, and information provided by other colleagues across the Scottish Government including Scottish Government publications such as:
- COVID-19: Children, young people and families – June 2021 Evidence Summary,
- COVID-19 Mitigation Measures Among Children and Young People in Scotland – Summary of the Evidence Base
- Coronavirus (COVID-19) - experiences of vulnerable children, young people, and parents: research
Evidence has also been gathered from The Impact of Covid-19 on children and young people in Scotland: 10 - 17 year olds published by Public Health Scotland.
Themes arising from the above include:
- Behavioural and emotional difficulties observed in young children
- Poor levels of social interaction
- Increased stress in 12 – 17 year olds
- Concern with the health impact of returning to school
- Increased loneliness
- The desire for clearer messaging on rules around meeting others
- Lower levels of mental health
- Restrictions on meetings others negatively impacting upon relationships and mental health
Due to the nature of the pandemic, there is necessarily less evidence than would usually be available to support associated policy development. However, there is significant evidence of young people's views through surveys undertaken by 3rd sector organisations. These have been referenced throughout, as appropriate.
Children and young people's views and experiences
There is clear evidence of children and young people's views and experiences of self-isolation and their views on COVID restrictions and mitigations gathered by 3rd sector organisations.
The development of the policy has benefited from taking into account the views and experiences of children and young people by drawing from surveys and reports such as the lockdown lowdown and the education recovery youth panel.
Themes reported in the findings of these surveys and consultations include:
- The desire to increase safety at school
- Issues with learner support availability at all school stages and difficulty with online learning
- Challenges with wearing face coverings
- Mental health, emotional and wellbeing concerns arising from self-isolation requirements
- Lack of opportunities to engage with others via meeting with friends/family, group working etc
- Differences in contact time with teachers across schools
- Challenges in being self-motivated in senior phase
- Lack of consistency between school and home
- Concern about transmitting the virus to others
As members of the Education Recovery Youth Panel children and young people were also invited to comment directly on drafts of the Reducing risks in schools guidance during development. Many of the issues outlined above are still considered a priority but panel members and those consulted were pleased with the direction of travel the guidance was taking.
Key Findings, including an assessment of the impact on children's rights, and how the measure will contribute to children's wellbeing
The policy impacts upon the following articles of the UNCRC:
- Article 2 - Non-discrimination
- Article 3 - Best interests of the child
- Article 6 - Life, survival and development
- Article 12 - Respect for the views of the child
- Article 13 - Freedom of expression
- Article 15 - Freedom of association
- Article 18(2 & 3) - Parental responsibilities and state assistance
- Article 23 - Children with disabilities
- Article 24 - Health and health services
- Article 28 - Right to education
- Article 29 - Goals of education
- Article 30 - Children of minorities/indigenous groups
- Article 31 - Leisure, play and culture
- Article 36 - Protection from exploitation or maltreatment
- Article 39 - Recovery and rehabilitation of child victims
The impact assessment found that policy changes to self-isolation, contact tracing and testing for U18 close contacts and minor adjustments to mitigation measures are expected to impact positively upon children and young people in general.
By increasing consistency of attendance at school as a consequence to the above policy changes and in line with clinical advice, children and young people will better benefit from:
- the increased safety conveyed by child protective factors at school,
- the health benefits inherent at schools as part of their role in promoting health, including social, emotional and mental wellbeing,
- in-person support for their learning and achievement
- the nurturing environment promoted by care and support services offered by the school environment,
- increased activity as a consequence of schools undertaking specific activities in relation to physical activity and sport, as part of the health and wellbeing curriculum and being health promoting schools.
- the respect of having their views about matters that concern them being recognised, such as their desire to return to a more consistent school routine,
- the responsibility of being empowered to protect their more consistent school routine by participating in the mitigation measures required to maintain a safe school environment, and
- increased inclusion as a result of more consistent schooling for all children that will promote school participation for all pupils with additional support available for the disadvantaged, for example, in the form of access to in-person care and support for those with additional support needs.
Where the assessment identified negative impacts, such as the impact of continued wearing of face coverings in school learners with additional support needs, including any level of hearing loss, and children and young people who are acquiring English, these are mitigated by supplementary guidance or mitigation measures to minimise any reduction in the rights and wellbeing of the child as laid out in the UNCRC and described in the Scottish Government's GIRFEC framework.
Monitoring and review
Mitigations will be kept under constant review, and if data and evidence suggest that any specific mitigations can be reduced or removed at an earlier stage advice will be provided to that effect.
Learning Directorate: Covid-19 Education Recovery Group Secretariat
Date: 4 Aug 2021
Deputy Director or equivalent:
Andrew Drought and Sam Anson
Deputy Director, Covid Education Strategy and Recovery Division
Date: 4 August 2021